Transfer Pricing Seminar 2018

The Inland Revenue Authority of Singapore (“IRAS”) released the 5th revision of the Singapore Transfer Pricing Guidelines on 23rd February 2018.  These revised guidelines provide the Singapore tax community with further understanding of the implementation of the amended transfer pricing legislation, which came about as a result of the Income Tax (Amendment) Act 2017 and the Income Tax (Transfer Pricing Documentation) Rules.  

The key changes introduced are:

• Clarification of the substance over form approach that allows the IRAS to re-characterise transactions
• Mandatory requirement to prepare contemporaneous transfer pricing documentation (TPD) from YA 2019 for Singapore taxpayers with annual revenue of more than S$ 10 million
• Penalties for not preparing contemporaneous TPD
• A 5% surcharge on TP adjustments regardless of whether tax is payable on the adjustments

Over 70 participants attended the seminar on 4 May 2018 and were provided with a comprehensive coverage of the recent transfer pricing developments for effectively managing compliance obligations going forward.

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